I contributed to an article on FCMs for Sapient Global Markets, see my writing page here for links and the PDF.

Precis:

The Dodd-Frank Act has already had a significant impact on the financial industry. One noteworthy change is the introduction of the Futures Commission Merchant (FCM) model to the OTC derivatives market. In this article, Corinna Athanasopoulos, Bill Hodgson and Gordon McDermid discuss the operational and legal implications of applying the FCM construct to a more bespoke OTC market.